Business ethics

At dsm-firmenich, our actions are guided by our company values and our commitment to observing the highest ethical standards.

As a company, we follow all applicable laws and regulations and promote a strong compliance culture, one in which all our employees feel they can openly raise any potential concerns without fear of retaliation.

On a quarterly basis at least, the Business Ethics team reports and escalates compliance issues and initative to the Group Ethics Committee (GEC), which oversees, assesses and enhances ethics and integrity across the company, based on our Code of Business Ethics and Group Policies. The GEC plays a crucial role in maintaining an ethical culture and ensuring that the organization operates with accountability. The GEC consists of:

• Chief Executive Officer

• Chief Financial Officer

• Chief Human Resources Officer

• Chief Legal, Risk and Compliance Officer (Chair)

• Head of Business Ethics (Secretary)

In 2025, our focus was on continuing to establish the foundations of our ethics and compliance framework, while ensuring that our program is strong, resilient, fit for purpose, and responsive to the evolving needs of our organization and our stakeholders. Our Code of Business Ethics and related policies set out our principles for acting ethically as a company. The framework covers the prevention and mitigation of bribery and corruption risks, the delivery of mandatory business ethics training, and the operation of a secure platform for reporting actual or suspected breaches of our ethical standards. These activities address the various ethics and compliance risks overseen by the Business Ethics team, with ultimate accountability residing with the Group Ethics Committee (GEC).

Integrity guides our choices, shapes our culture, and earns the trust we build every day.

Identifying and managing bribery and corruption risks

A key focus is preventing corruption and bribery by establishing effective counter-measures. Our Anti-Bribery and Corruption policy shapes our internal regulatory framework by defining principles and areas for attention. From this, we derive a set of standards that address the main risk areas. Moreover, a multi-disciplinary third-party risk assessment was conducted to gauge the risk of bribery and corruption, among other things. As a result, we implemented further process improvements and identified areas requiring further attention. Reflecting enhancements made in 2025 and our focus on preventing corruption and bribery through effective measures, during the year we:

• Continued our review of donations and sponsorships and the suitability of our philanthropic initiatives and partners

• Supplemented the Conflict of Interest standard with a section providing guidance on managing potential or actual conflicts of interest during the recruitment process

• Launched a new Gifts and Entertainment standard, replacing earlier requirements to cover the giving and receiving of gifts and participation in entertainment activities with individuals outside dsm-firmenich

• Commenced work on a Group standard to harmonize our Anti-Bribery and Corruption Third-Party Risk checks. This ensures due diligence vis-à-vis our Business Partners

The gathering of data through dedicated mechanisms linked to each of the aforementioned standards also helps the company to ensure their consistent application, to identify trends, analyze data relationships, and proactively address potential risks.

The aim of these standards is not only to establish a set of rules to protect the company and its workforce but also to provide clear guidance to employees on the part they play in fostering an ethical business environment. The standards are shared via dedicated communication and training programs, complementing the imperative learnings enshrined in our Group mandatory trainings.

Group mandatory trainings

Training mitigates the risk of breaches of our ethical standards. In 2025, we worked on creating a strong and comprehensive mandatory training program, targeting 100% completion rates.

Between October 2024 and August 2025, we successfully launched five Group mandatory trainings: Code of Business Ethics (CoBE), Anti-Bribery and Corruption (ABC), People-Centric (Work Respect and Harassment Prevention), Physical and Cyber Security, and Safety, Health and Environment (SHE). The training cycle follows a two-year review period. All employees are required to complete the five Group mandatory trainings. By the end of 2025, all five mandatory trainings for internal employees achieved a completion rate above 96%. This demonstrates strong engagement and commitment to compliance across the organization. To ensure accessibility and effectiveness, the trainings were delivered via a user-friendly online platform for all employees, complemented by dedicated classroom sessions for shop-floor teams.

Legal targeted trainings

In addition to the Group Mandatory trainings, for all employees, Legal targeted trainings were assigned to specific groups of employees across the organization, typically those focused on core functions or roles. Between August 2024 and June 2025, we successfully launched three Legal targeted trainings: Competition Law (in two launch waves), Privacy Awareness (in two launch waves), and Trade Compliance.